Preserving trust is a core value. Hoffman Benefit Services, Inc. (HSBI) recognizes that clients expect us to protect the information they provide us and to use it responsibly. We are strongly committed to fulfilling the trust that is the foundation of our client's expectations. For that reason we have adopted and adhere to the following policy regarding the privacy of client personal information.

INFORMATION THAT WE COLLECT

We collect nonpublic personal information about clients from some or all of the following sources:

• Information we receive from clients on fact finding questionnaires and product applications;
• Client transactions with us, our affiliates, and those product sponsors with whom we have appointments or other arrangements for the provision of service to clients;
• Consumer reporting agencies; and
• Affiliated and unaffiliated product sponsors with whom we have selling relationships and whose product our clients own.

INFORMATION THAT WE DISCLOSE

We will not share nonpublic personal information concerning our customers or former customers for marketing purposes, except as permitted by law, as described below. We will not share nonpublic personal information concerning our current or former customers with affiliated or unaffiliated third parties, any of the nonpublic personal information that we collect, as identified above.

Generally, we disclose customer nonpublic personal information to affiliates and unaffiliated third parties that provide services to us in order that we may more effectively and efficiently service their account. We also disclose nonpublic personal information to affiliated or unaffiliated third parties with whom we have contractual relationships that allow us to provide the products or services that our clients have requested through us. Examples of third parties with whom we may share nonpublic personal information include:

Third party advisory/administration firms with whom we have relationships for the management of customer accounts; Insurance Companies and other product sponsors to affect purchases and sales and allow the servicing of client accounts

STEPS WE TAKE TO PROTECT CLIENT INFORMATION

We have security practices and procedures in place to prevent unauthorized use or access to client nonpublic personal information. Internally, client information is only available to those employees requiring access to process or service transactions with us, and those fulfilling compliance, legal or audit functions on our client's behalf. Our computer systems utilize password protection to prevent access by unauthorized persons and we employ other physical, electronic and procedural safeguards to ensure the protection of client information in accordance with state and federal privacy regulations.